Homeland Security

Management and Programmatic Challenges Facing the Department of Homeland Security Gao ID: GAO-07-833T May 10, 2007

The Department of Homeland Security (DHS) plays a key role in leading and coordinating--with stakeholders in the federal, state, local, and private sectors--the nation's homeland security efforts. GAO has conducted numerous reviews of DHS management functions as well as programs including transportation and border security, immigration enforcement and service delivery, and disaster preparation and response. This testimony addresses: (1) why GAO designated DHS's implementation and transformation as a high-risk area, (2) specific management challenges that DHS continues to face, (3) examples of the program challenges that DHS faces, and (4) actions DHS should take to strengthen its implementation and transformation efforts.

GAO designated implementing and transforming DHS as high risk in 2003 because DHS had to transform and integrate 22 agencies--several with existing program and management challenges--into one department, and failure to effectively address its challenges could have serious consequences for our homeland security. Despite some progress, this transformation remains high risk. Managing the transformation of an organization of the size and complexity of DHS requires comprehensive planning and integration of key management functions that will likely span a number of years. DHS has made some progress in these areas, but much additional work is required to help ensure sustainable success. DHS has also issued guidance and plans to assist management integration on a function by function basis, but lacks a comprehensive integration strategy with overall goals, a timeline, appropriate responsibility and accountability determinations, and a dedicated team to support its efforts. The latest independent audit of DHS's financial statements showed that its financial management systems still do not conform to federal requirements. DHS has also not institutionalized an effective strategic framework for information management, and its human capital and acquisition systems require further attention to ensure that DHS allocates resources economically, effectively, ethically, and equitably. Since GAO's 2007 high-risk update, DHS has continued to strengthen program activities but still faces a range of programmatic and partnering challenges. To help ensure its missions are achieved, DHS must overcome continued challenges related to such issues as cargo, transportation, and border security; systematic visitor tracking; efforts to combat the employment of illegal aliens; and outdated Coast Guard asset capabilities. Further, DHS and the Federal Emergency Management Agency need to continue to develop clearly defined leadership roles and responsibilities; necessary disaster response capabilities; accountability systems to provide effective services while protecting against waste, fraud, and abuse; and the ability to conduct advance contracting for emergency response goods, supplies, and services. DHS has not produced a final corrective action plan specifying how it will address its many management challenges. Such a plan should define the root causes of known problems, identify effective solutions, have management support, and provide for substantially completing corrective measures in the near term. It should also include performance metrics and milestones, as well as mechanisms to monitor progress. It will also be important for DHS to become more transparent and minimize recurring delays in providing access to information on its programs and operations so that Congress, GAO, and others can independently assess its efforts. DHS may require a chief management official, with sufficient authority, dedicated to the overall transformation process to help ensure sustainable success over time.

GAO-07-833T, Homeland Security: Management and Programmatic Challenges Facing the Department of Homeland Security This is the accessible text file for GAO report number GAO-07-833T entitled 'Homeland Security: Management and Programmatic Challenges Facing the Department of Homeland Security' which was released on May 10, 2007. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. Because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. Testimony Before the Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of Columbia, Senate Committee on Homeland Security and Governmental Affairs: United States Government Accountability Office: GAO: For Release on Delivery: Expected at 9:00 a.m. EDT: Thursday, May 10, 2007: Homeland Security: Management and Programmatic Challenges Facing the Department of Homeland Security: Statement of David M. Walker: Comptroller General of the United States: U.S. Government Accountability Office: GAO-07-833T: GAO Highlights: Highlights of GAO-07-833T, a testimony before the Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of Columbia, Committee on Homeland Security and Government al Affairs, U.S. Senate Why GAO Did This Study: The Department of Homeland Security (DHS) plays a key role in leading and coordinating”with stakeholders in the federal, state, local, and private sectors”the nation‘s homeland security efforts. GAO has conducted numerous reviews of DHS management functions as well as programs including transportation and border security, immigration enforcement and service delivery, and disaster preparation and response. This testimony addresses: * why GAO designated DHS‘s implementation and transformation as a high- risk area, * specific management challenges that DHS continues to face, * examples of the program challenges that DHS faces, and * actions DHS should take to strengthen its implementation and transformation efforts. What GAO Found: GAO designated implementing and transforming DHS as high risk in 2003 because DHS had to transform and integrate 22 agencies”several with existing program and management challenges”into one department, and failure to effectively address its challenges could have serious consequences for our homeland security. Despite some progress, this transformation remains high risk. Managing the transformation of an organization of the size and complexity of DHS requires comprehensive planning and integration of key management functions that will likely span a number of years. DHS has made some progress in these areas, but much additional work is required to help ensure sustainable success. DHS has also issued guidance and plans to assist management integration on a function by function basis, but lacks a comprehensive integration strategy with overall goals, a timeline, appropriate responsibility and accountability determinations, and a dedicated team to support its efforts. The latest independent audit of DHS‘s financial statements showed that its financial management systems still do not conform to federal requirements. DHS has also not institutionalized an effective strategic framework for information management, and its human capital and acquisition systems require further attention to ensure that DHS allocates resources economically, effectively, ethically, and equitably. Since GAO‘s 2007 high-risk update, DHS has continued to strengthen program activities but still faces a range of programmatic and partnering challenges. To help ensure its missions are achieved, DHS must overcome continued challenges related to such issues as cargo, transportation, and border security; systematic visitor tracking; efforts to combat the employment of illegal aliens; and outdated Coast Guard asset capabilities. Further, DHS and the Federal Emergency Management Agency need to continue to develop clearly defined leadership roles and responsibilities; necessary disaster response capabilities; accountability systems to provide effective services while protecting against waste, fraud, and abuse; and the ability to conduct advance contracting for emergency response goods, supplies, and services. DHS has not produced a final corrective action plan specifying how it will address its many management challenges. Such a plan should define the root causes of known problems, identify effective solutions, have management support, and provide for substantially completing corrective measures in the near term. It should also include performance metrics and milestones, as well as mechanisms to monitor progress. It will also be important for DHS to become more transparent and minimize recurring delays in providing access to information on its programs and operations so that Congress, GAO, and others can independently assess its efforts. DHS may require a chief management official, with sufficient authority, dedicated to the overall transformation process to help ensure sustainable success over time. What GAO Recommends: While this testimony contains no new recommendations, GAO has made numerous prior recommendations to DHS in reports addressing the issues identified in this statement. DHS generally concurred with these recommendations; however it is not clear to what extent these recommendations are being implemented. [Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-833T]. To view the full product, including the scope and methodology, click on the link above. For more information, contact Norman Rabkin at (202) 512-8777 or rabkinn@gao.gov or Bernice Steinhardt, at 202-512-6806 or steinhardtb@gao.gov [End of section] Mr. Chairman and Members of the Subcommittee: I appreciate the opportunity to appear before the subcommittee to address management and programmatic challenges facing the Department of Homeland Security (DHS). I have spoken extensively about the fiscal crisis our nation faces with the coming retirement of the baby boom generation and the related growth in entitlement spending. The current financial condition in the United States is worse than is widely understood and is not sustainable. Meeting the long-term fiscal challenge will require (1) significant entitlement reform to change the path of those programs; (2) reprioritizing, restructuring and constraining other spending programs; and (3) additional revenues--such as through a reformed tax system. These efforts will require bipartisan cooperation and compromise. Irrespective of our fiscal situation, it is important for federal departments--including DHS--to operate as efficiently and effectively as possible in carrying out their missions. At the same time, we also face new and uncertain threats to our security, both overseas and at home, that require continued attention. Without this focus, the consequences can be catastrophic. We designated the implementation and transformation of DHS as a high-risk area in 2003 and continued that designation in our 2005 update. In my testimony today, I will explain why we decided to maintain this area on our 2007 high risk list, focusing on four areas: * why we originally designated DHS's implementation and transformation as a high-risk area, * specific management challenges that DHS continues to face, * examples of the program challenges that DHS faces, and: * actions DHS should take to strengthen its implementation and transformation efforts. My comments today are based on our wide-ranging work on DHS since the 2005 high-risk update, as well as our institutional knowledge of homeland security and various government organizational and management issues. We conducted our work in accordance with generally accepted government auditing standards. A listing of GAO reports related to the transformation, management, and program challenges discussed in this statement are contained in Appendix 1. Summary: We first designated DHS's implementation and transformation as high risk in 2003 because 22 disparate agencies had to transform and integrate into one department. Many of these individual agencies were facing their own management and mission challenges. But most importantly, the failure to effectively address DHS's management challenges and program risks could have serious consequences for our homeland security as well as our economy. We kept the DHS implementation and transformation on the high-risk list in 2005 because serious transformation challenges continued to hinder DHS's success. Since then, our and the DHS Inspector General's (IG) reports have documented DHS's progress and remaining challenges in transforming into an effective, integrated organization. For example, in the management area, DHS has developed a strategic plan, is working to integrate some management functions, and has continued to form necessary partnerships to achieve mission success. Despite these efforts, however, DHS implementation and transformation remain on the 2007 high-risk list because numerous management challenges continue to exist. For example, * Although DHS has issued guidance and plans to assist management integration on a function by function basis, DHS lacks a comprehensive management integration strategy with overall goals, timelines, and a team dedicated to support its integration efforts. * The DHS strategic plan addresses five of six Government Performance and Results Act required elements and takes into account its non- homeland security missions, such as responding to natural disasters. However, it had only limited consultation with key stakeholders, thus missing an opportunity to create a shared understanding of goals and priorities. * Several DHS programs have not developed outcome-based measures to assess performance. * While the Secretary of DHS has expressed a commitment to risk management, DHS has not performed comprehensive risk assessments in transportation, trade, critical infrastructure, or the immigration and customs systems to guide resource allocation decisions. * Since its creation, DHS has been unable to obtain an unqualified or "clean" audit opinion on its financial statements. The auditors continue to report material internal control weaknesses and that DHS's financial systems do not substantially comply with federal requirements. These weaknesses highlight the concern that DHS may not be able to account for all of its funding and resources or have reliable financial information for management and budget purposes. * DHS has not institutionalized an effective strategic framework for information management to, among other things, guide technology investments, and despite some progress, DHS's human capital--the centerpiece of its transformation efforts--and acquisition systems will require continued attention to help prevent waste and to ensure that DHS can allocate its resources economically, efficiently, effectively, ethically, and equitably. DHS has taken some actions to strengthen program activities in areas such as cargo, transportation, and border security; Coast Guard acquisition management; advance contracting for goods and services for disaster preparedness; and immigration services. However, DHS continues to face a range of programmatic and partnering challenges. To help ensure its missions are achieved, DHS must overcome continued challenges related to: * strengthening cargo and passenger screening, visitor tracking, efforts to combat the employment of illegal aliens, and outdated Coast Guard asset capabilities; * balancing its homeland security and other missions, such as disaster preparedness; and: * clearly defining leadership roles and responsibilities, developing necessary disaster response capabilities, and establishing accountability systems to provide effective services while protecting against waste, fraud, and abuse at the Federal Emergency Management Agency (FEMA). To be removed from GAO's high-risk list,[Footnote 1] agencies must do three things. First, they have to produce a corrective action plan that defines the root causes of identified problems, identifies effective solutions to those problems, and provides for substantially completing corrective measures in the near term. Such a plan should include performance metrics and milestones, as well as mechanisms to monitor progress. In the spring of 2006, DHS provided us with a draft corrective action plan that did not contain key elements we have identified as necessary for an effective corrective action plan, including specific actions to address identified objectives. As of May 2007, DHS has not submitted a corrective action plan to OMB. According to OMB, this is one of the few high-risk areas that has not produced a final corrective action plan. Second, agencies must demonstrate significant progress in addressing the problems identified in their corrective action plan. To date, DHS has not been transparent in its efforts to strengthen its management areas and mission functions. While much of its sensitive work needs to be guarded from improper disclosure, DHS has not been receptive towards oversight and its delays in providing Congress and us with access to various documents and officials have impeded the timeliness of our work. We have recently worked with DHS management, including the Secretary and the Undersecretary for Management, to establish a more cooperative and efficient process--for example, reviewing sensitive documents at a particular agency location--in an effort to not only to maintain a productive working relationship with the department, but also to meet the needs of our congressional requesters in a timely manner. Finally, agencies, in particular top leadership, must demonstrate a commitment to achieve any remaining key objectives and sustain various improvements in their performance over the long term. Although DHS leaders have expressed their intent to integrate legacy agencies into the new department, they have not dedicated the resources needed to oversee this effort and have not been responsive to many directions from Congress and recommendations from study groups and accountability organizations like the IGs and GAO. While this testimony contains no new recommendations, GAO has made numerous prior recommendations to DHS in reports addressing the issues identified in this statement. DHS generally concurred with these recommendations; however it is not clear to what extent these recommendations are being implemented. Background: In an effort to strengthen homeland security following the September 11, 2001, terrorist attacks on the United States, President Bush issued the National Strategy for Homeland Security in July 2002 and signed legislation creating DHS in November 2002.[Footnote 2] The strategy set forth the overall objectives, mission areas, and initiatives to prevent terrorist attacks within the United States; reduce America's vulnerability to terrorism; and minimize the damage and assist in the recovery from attacks that may occur. DHS, which began operations in March 2003, represented a fusion of 22 federal agencies to coordinate and centralize the leadership of many homeland security activities under a single department. Although the National Strategy for Homeland Security identified that many other federal departments (and other nonfederal stakeholders) are involved in homeland security activities, DHS has the dominant role in implementing the strategy. The strategy identified 6 mission areas and 43 initiatives. DHS was designated as the lead federal agency for 37of the 43 initiatives, and has activities under way in 40 of the 43 initiatives. The Homeland Security Act of 2002, which created DHS, represented a historic moment of almost unprecedented action by the federal government to fundamentally transform how the nation thinks of homeland security, including how it protects itself from terrorism. Also significant was the fact that many of the 22 departments brought together under DHS were not focused on homeland security missions prior to September 11, 2001. Rarely in the country's past had such a large and complex reorganization of government occurred or been developed with such a singular and urgent purpose. The creation of DHS represented a unique opportunity to transform a disparate group of agencies with multiple missions, values, and cultures into a strong and effective cabinet department whose goals are to, among other things, protect U.S. borders and infrastructure, improve intelligence and information sharing, and prevent and respond to potential terrorist attacks. Together with this unique opportunity, however, came a significant risk to the nation that could occur if the department's implementation and transformation efforts were not successful. Mission areas designated as high risk have national significance, while other areas designated as high risk represent management functions that are important for agency performance and accountability. The identified areas can have a qualitative risk that may be detrimental to public health or safety, national security, and economic growth, or a fiscal risk due to the size of the program in question. Examples of high-risk areas include federal governmentwide problems, like human capital management; large programs, like Social Security, Medicaid, and Medicare; and more narrow issues, such as contracting at a specific agency. The DHS transformation is unique in that it involves reorganization, management, and program challenges simultaneously. DHS's Transformation: We first designated DHS's transformation as high risk in January 2003 based on three factors. First, DHS faced enormous challenges in implementing an effective transformation process, developing partnerships, and building needed management capacity because it had to effectively combine 22 agencies with an estimated 170,000 employees into one department. Second, DHS faced a broad array of operational and management challenges that it inherited from its component legacy agencies. For example, many of the major components that were merged into the department, including the Immigration and Naturalization Service, the Transportation Security Administration, the Customs Service, the Federal Emergency Management Agency, and the Coast Guard, brought with them existing challenges in areas such as strategic human capital, information technology, and financial management. Finally, DHS's national security mission was of such importance that the failure to effectively address its management challenges and program risks could have serious consequences on our intergovernmental system, the health and safety of our citizens, and our economy. Our prior work on mergers and acquisitions, undertaken before the creation of DHS, found that successful transformations of large organizations, even those faced with less strenuous reorganizations than DHS, can take years to achieve.[Footnote 3] On the basis of the need for more progress in its transformation efforts, DHS's implementation and transformation stayed on our high-risk update for 2005, and remained on the high-risk list in 2007. Further, in November of 2006, we provided the congressional leadership a listing of government programs, functions, and activities that warrant further congressional oversight.[Footnote 4] Among the issues included were DHS integration and transformation efforts. DHS Must Address Key Management Challenges: Managing the transformation of an organization of the size and complexity of DHS requires comprehensive planning, integration of key management functions across the department, and partnering with stakeholders across the public and private sectors. DHS has made some progress in each of these areas, but much additional work is required to help ensure sustainable success. Apart from these integration efforts, however, a successful transformation will also require DHS to follow through on its initial actions of building capacity to improve the management of its financial and information technology systems, as well as its human capital and acquisition efforts. DHS Transformation and Integration: Thorough planning is important for DHS to successfully transform and integrate the management functions of 22 disparate agencies into a common framework that supports the organization as a whole. Our past work has identified progress DHS has made in its planning efforts.[Footnote 5] For example, the DHS strategic plan addresses five of six Government Performance and Results Act required elements and takes into account its non-homeland security missions, such as responding to natural disasters. Furthermore, several DHS components have developed their own strategic plans or strategic plans for missions within their areas of responsibility. For example, U.S. Immigration and Customs Enforcement (ICE) has produced an interim strategic plan that identifies its goals and objectives, and U.S. Customs and Border Protection (CBP) developed a border patrol strategy and an anti-terrorism trade strategic plan. However, deficiencies in DHS's planning efforts remain. A DHS-wide transformation strategy should include a strategic plan that identifies specific budgetary, human capital, and other resources needed to achieve stated goals. The strategy should also involve key stakeholders to create a shared understanding of goals and priorities. DHS's existing strategic plan lacks these linkages, and DHS has not effectively involved stakeholders in the development of the plan. DHS has also not completed other important planning-related activities. For example, some of DHS's components have not developed adequate outcome-based performance measures or comprehensive plans to monitor, assess, and independently evaluate the effectiveness of their plans and performance. Integrating core management functions like financial, information technology, human capital, and procurement is also important if DHS is to transform itself into a cohesive, high-performing organization. However, DHS lacks a comprehensive management integration strategy with overall goals, a timeline, appropriate responsibility and accountability determinations, and a dedicated team to support its management integration efforts. In 2005, we recommended that DHS establish implementation goals and a timeline for its management integration efforts as part of a comprehensive integration strategy, a key practice to help ensure success for a merger or transformation. Although DHS has issued guidance and plans to assist management integration on a function by function basis, it has not developed a plan that clearly identifies the critical links that should occur across these functions, the necessary timing to make these links occur, how these interrelationships will occur, and who will drive and manage them. In March 2007 testimony before the House Homeland Security Committee, DHS's Undersecretary for Management supported our recommendation on the need for a comprehensive management integration strategy for the department. The Undersecretary stated that he was reviewing DHS's progress against its individual plans and guidance for its management functions that would be part of such a comprehensive strategy. In addition, although DHS had established a Business Transformation Office that reported to the Under Secretary for Management to help monitor and look for interdependencies among the individual functional management integration efforts, that office was not responsible for leading and managing the coordination and integration itself. We understand that the Business Transformation Office has been recently eliminated due to a lack of funding. In addition to the Business Transformation Office, we have recommended that Congress continue to monitor whether it needs to provide additional leadership authorities to the DHS Under Secretary for Management or create a Chief Operating Officer/Chief Management Officer (COO/CMO) position that could help elevate, integrate, and institutionalize DHS's management initiatives. Legislation was introduced in this session and passed by the Senate to create a Deputy Secretary of Homeland Security for Management, a CMO position.[Footnote 6] On April 24, 2007, I sponsored a forum on implementing COO/CMO positions in select federal departments and agencies, as part of a broader study examining issues associated with implementing these positions in response to a bipartisan request from this subcommittee. Forum participants included former and current government executives, and officials from private businesses and nonprofit organizations. The forum discussion focused on criteria for determining the type of COO/ CMO position that should be established in selected entities and how to implement the position, including qualifications, appointment processes, roles and responsibilities, and reporting relationships. In addition to the forum, we have also learned about the experiences of organizations that have positions similar to a COO/CMO through several case study reviews. We expect to issue our full report to the subcommittee in early September 2007. Finally, DHS cannot successfully achieve its homeland security mission without working with other entities that share responsibility for securing the homeland. Partnering for progress with other governmental agencies and private sector entities is central to achieving its missions. Since 2005, DHS has continued to form necessary partnerships and has undertaken a number of coordination efforts with private sector entities. These include, for example, partnering with (1) airlines to improve aviation passenger and cargo screening, (2) the maritime shipping industry to facilitate containerized cargo inspection, (3) financial institutions to follow the money trail in immigration and customs investigations, and (4) the chemical industry to enhance critical infrastructure protection at such facilities.[Footnote 7] In addition, FEMA has worked with other federal, state, and local entities to improve planning for disaster response and recovery. However, partnering challenges continue as DHS seeks to form more effective partnerships to leverage resources and more effectively carry out its homeland security responsibilities. For example, because DHS has only limited authority to address security at chemical facilities, it must continue to work with the chemical industry to ensure that it is assessing vulnerabilities and implementing security measures. Also, while TSA has taken steps to collaborate with federal and private sector stakeholders in the implementation of its Secure Flight program, these stakeholders stated that TSA has not provided them with the information they would need to support TSA's efforts as they move forward with the program. Financial Management and Internal Controls: DHS has made modest progress in addressing financial management and internal control weaknesses and continues to face significant challenges in these areas. For example, since its creation, DHS has been unable to obtain an unqualified or "clean" audit opinion on its financial statements. The independent auditor's report cited 10 material weaknesses--i.e., significant deficiencies in DHS's internal controls--showing no decrease from fiscal year 2005. These weaknesses included financial management oversight, financial reporting, financial systems security, and budgetary accounting. Furthermore, the report found two other reportable conditions and instances of non- compliance with eight laws and regulations, including the Federal Managers' Financial Integrity Act of 1982, the Federal Financial Management Improvement Act of 1996, and the Federal Information Security Management Act of 2002.[Footnote 8] While there continue to be material weaknesses in its financial management systems, DHS has made some progress in this area. For example, the independent auditor's fiscal year 2006 report noted that DHS had made improvements at the component level to improve financial reporting during fiscal year 2006, although many challenges were remaining. Also, DHS and its components have reported developing corrective action plans to address the specific material internal control weaknesses identified. In addition to the independent audits, we have done work to assess DHS's financial management and internal controls. For example, in 2004, we reviewed DHS's progress in addressing financial management weaknesses and integrating its financial systems.[Footnote 9] Specifically, we identified weaknesses in the financial management systems DHS inherited from the 22 component agencies, assessed DHS's progress in addressing these weaknesses, identified plans DHS had to integrate with its financial management systems, and reviewed whether the planned systems DHS was developing would meet the requirements of relevant financial management improvement legislation. On the basis of our work, we recommended that DHS (1) give sustained attention to addressing previously reported material weaknesses, reportable conditions, and observations and recommendations; (2) complete development of corrective action plans for all material weaknesses, reportable conditions, and observations and recommendations; (3) ensure that internal control weaknesses are addressed at the component level if they were combined or reclassified at the departmentwide level; and (4) maintain a tracking system of all auditor-identified and management- identified control weaknesses. These recommendations are still relevant today. Information Technology: A departmentwide information technology (IT) governance framework-- including controls (disciplines) aimed at effectively managing IT- related people, processes, and tools--is vital to DHS's transformation efforts. These controls and disciplines include: * having and using an enterprise architecture, or corporate blueprint, as an authoritative frame of reference to guide and constrain IT investments; * defining and following a corporate process for informed decision making by senior leadership about competing IT investment options; * applying system and software development and acquisition discipline and rigor when defining, designing, developing, testing, deploying, and maintaining systems; * establishing a comprehensive information security program to protect its information and systems; * having sufficient people with the right knowledge, skills, and abilities to execute each of these areas now and in the future; and: * centralizing leadership for extending these disciplines throughout the organization with an empowered Chief Information Officer.[Footnote 10] DHS has made progress in each of these areas, but additional work is needed to further enhance its IT governance framework and implement our related recommendations. For example, the June 2006 version of DHS's enterprise architecture, while an improvement over prior versions, still lacks important architecture content and limits DHS's ability to guide and constrain IT investments, among other things.[Footnote 11] With respect to IT investment management, DHS has established management structures but has not, for example, fully implemented key practices needed to effectively oversee and control department investments--putting the department at increased risk of its programs not delivering promised mission capabilities and benefits. DHS stated it is working on improving its investment management process.[Footnote 12] DHS has taken other measures to enhance IT governance as well, such as completing a comprehensive inventory of its major information systems (though a comprehensive information security program is still needed), organizing IT leadership roles and responsibilities under the CIO, and initiating strategic planning for IT human capital (an area where we have ongoing work to assess related strategic planning efforts and progress made). In addition to efforts undertaken in these areas, our reviews of key nonfinancial systems show that DHS has not consistently employed a range of system acquisition management disciplines, such as reliable cost-estimating practices and meaningful performance measurements. We have made a number of recommendations in this and other areas, including work related to deploying and operating IT system and infrastructure in support of DHS's core mission and operations. Implementation of many of our recommendations has been slow. Until DHS fully establishes and consistently implements the full range of IT management disciplines embodied in its framework and related to federal guidance and best practices, it will be challenged in its ability to effectively manage and deliver programs. Human Capital Systems: DHS has made some progress in transforming its human capital systems, but more work remains.[Footnote 13] Some of the most pressing human capital challenges at DHS include (1) successfully completing its ongoing transformation; (2) forging a unified results-oriented culture across the department (line of sight); (3) linking daily operations to strategic outcomes; (4) rewarding individuals based on individual, team, unit, and organizational results; (5) obtaining, developing, providing incentives to, and retaining needed talent; and most importantly, (6) leadership at the top, to include a chief operating officer or chief management officer. Moreover, employee morale is low, as measured by recent results in the 2006 Federal Human Capital Survey, which can have an impact on the progress of DHS's transformation and integration. DHS scored at the bottom or near the bottom of all federal agencies in the four areas which provide the standards of success for agencies to measure their progress and achievements in managing their workforces. These four areas include (1) leadership and knowledge management, (2) results-oriented performance culture, (3) talent management, and (4) job satisfaction. As we have reported, people are at the center of any serious change management initiative, and addressing the "people" element and employee morale issues is the key to a successful merger and transformation. Strategic human capital management is the centerpiece of any transformation effort. In 2005, we reported that DHS had initiated strategic human capital planning efforts and published proposed regulations for a modern human capital management system.[Footnote 14] We also reported that DHS's leadership was committed to the human capital system design process and had formed teams to implement the resulting regulations. Since our report, DHS has finalized its human capital regulations and it is vital that DHS implement its human capital system effectively.[Footnote 15] In April 2007, DHS issued its fiscal year 2007 and 2008 Human Capital Operational Plan, which identifies five department priorities: hiring and retaining a talented and diverse workforce, creating a DHS-wide culture of performance, creating high-quality learning and development programs for DHS employees, implementing a DHS-wide integrated leadership system, and being a model of human capital service excellence. DHS officials explained that the Human Capital Operating Plan encompasses the initiatives of the previous human capital management system, MAXHR, but also outlines a more comprehensive human resources program. GAO has not yet reviewed DHS's new Human Capital Operational Plan to see if it addresses our prior recommendations. However, we expect to examine this plan. Further, since our 2005 update, DHS has taken some actions to integrate the legacy agency workforces that make up its components. For example, it standardized pay grades for criminal investigators at ICE and developed promotion criteria for investigators and CBP officers that equally recognize the value of the experience brought to ICE and CBP by employees of each legacy agency. DHS also made progress in establishing human capital capabilities for the US-VISIT program, which should help ensure that it has sufficient staff with the necessary skills and abilities to implement the program effectively. CBP also developed training plans that link its officer training to CBP strategic goals. Despite these efforts, however, DHS must still (1) create a clearer crosswalk between departmental training goals and objectives and DHS's broader organizational and human capital goals, and (2) develop appropriate training performance measures and targets for goals and strategies identified in its departmentwide strategic training plan. We have also made recommendations to specific program offices and organizational entities to help ensure that human capital resources are provided to improve the effectiveness of management capabilities, and that human capital plans are developed that clearly describe how these components will recruit, train, and retain staff to meet their growing demands as they expand and implement new program elements. We are completing a review of selected human capital issues and plan to report on our results soon. This report will discuss information on: attrition rates at DHS; senior-level vacancies at DHS; DHS's use of human capital flexibilities, including the Intergovernmental Personnel Act, and personal services contracts; and DHS's compliance with the Federal Vacancies Reform Act of 1998. Acquisition Management: DHS has made some progress but continues to face challenges in creating an effective, integrated acquisition organization. Since its inception in March 2003, DHS made early progress in implementing a strategic sourcing program to increase the effectiveness of its buying power and in creating a small business program. These programs have promoted an environment in which there is a collaborative effort toward the common goal of an efficient, unified organization. Strategic sourcing allows DHS components to formulate purchasing strategies to leverage buying power and increase savings for a variety of products like office supplies, boats, energy, and weapons, while its small business program works to ensure small businesses can compete effectively for the agency's contract dollars. However, DHS's progress toward creating a unified acquisition organization has been hampered by policy decisions. In March 2005, we reported that an October 2004 management directive, Acquisition Line of Business Integration and Management, while emphasizing the need for a unified, integrated acquisition organization, relies on a system of dual accountability between the chief procurement officer and the heads of the departments to make this happen.[Footnote 16] This situation has created ambiguity about who is accountable for acquisition decisions. We also found that the various acquisition organizations within DHS are still operating in a disparate manner, with oversight of acquisition activities left primarily up to each individual component. Specifically, we reported that (1) there were components exempted from the unified acquisition organization, (2) the chief procurement officer had insufficient staff for departmentwide oversight, and (3) staffing shortages led the office of procurement operations to rely extensively on outside agencies for contracting support.[Footnote 17] In December 2005, DHS established an acquisition oversight program to provide comprehensive insight into each component's acquisition programs. This oversight program involves a series of reviews which are currently being implemented. However, accountability concerns remain. In March 2005, we recommended that, among other things, the Secretary of Homeland Security provide the Office of the Chief Procurement Officer with sufficient resources and enforcement authority to enable effective departmentwide oversight of acquisition policies and procedures, and to revise the October 2004 management directive to eliminate reference to the Coast Guard and Secret Service as being exempt from complying with the directive. In September 2006, DHS reported on planned increases in staffing for the Office of the Chief Procurement Officer, but we expressed concern that the authority of the Chief Procurement Officer had not been addressed.[Footnote 18] Unless DHS addresses these challenges, it is at risk of continuing to exist as a fragmented acquisition organization. Because some of DHS's components have major, complex acquisition programs--for example, the Coast Guard's Deepwater program (designed to replace or upgrade its cutters and aircraft) and CBP's Secure Border Initiative--DHS needs to improve the oversight of contractors and should adhere to a rigorous management review process. Programmatic Challenges Facing DHS: DHS continues to face challenges, many of which were inherited from its component legacy agencies, in carrying out its programmatic activities. These challenges include enhancing transportation security, strengthening the management of U.S. Coast Guard acquisitions and meeting the Coast Guard's new homeland security missions, improving the regulation of commercial trade while ensuring protection against the entry of illegal goods and dangerous visitors at U.S. borders and ports of entry, and improving enforcement of immigration laws, including worksite immigration laws, and the provision of immigration services. DHS must also effectively coordinate the mitigation and response to all hazards, including natural disaster planning, response, and recovery. DHS has taken actions to address these challenges, for example, by strengthening passenger and baggage screening, increasing the oversight of Coast Guard acquisitions, more thoroughly screening visitors and cargo, dedicating more resources to immigration enforcement, becoming more efficient in the delivery of immigration services, and conducting better planning for disaster preparation. However, challenges remain in each of these major mission areas. Transportation Security: Despite progress in this area, DHS continues to face challenges in effectively executing transportation security efforts. We have recommended that the Transportation Security Administration (TSA) more fully integrate a risk management approach--including assessments of threat, vulnerability, and criticality--in prioritizing security efforts within and across all transportation modes; strengthen stakeholder coordination; and implement needed technological upgrades to secure commercial airports.[Footnote 19] DHS has made progress in all of these areas, particularly in aviation, but must expand its security focus more towards surface modes of transportation and continue to seek best practices and coordinated security efforts with the international community. DHS and TSA have taken numerous actions to strengthen commercial aviation security, including strengthening passenger and baggage screening, improving aspects of air cargo security, and strengthening the security of international flights and passengers bound for the United States.[Footnote 20] For example, TSA increased efforts to measure the effectiveness of airport screening systems through covert testing and other means and has worked to enhance passenger and baggage screener training. TSA also improved its processes for identifying and responding to threats onboard commercial aircraft and has modified airport screening procedures based on risk. Despite this progress, however, TSA continues to face challenges in implementing a program to match domestic airline passenger information against terrorist watch lists, fielding needed technologies to screen airline passengers for explosives, and strengthening aspects of passenger rail security.[Footnote 21] In addition, TSA has not developed a strategy, as required, for securing the various modes of transportation. As a result, rail and other surface transportation stakeholders are unclear regarding what TSA's role will ultimately be in establishing and enforcing security requirements within their transportation modes. We have recommended that TSA more fully integrate risk-based decision making within aviation and across all transportation modes, strengthen passenger prescreening, and enhance rail security efforts. We have also recommended that TSA work to develop sustained and effective partnerships with other government agencies, the private sector, and international partners to coordinate security efforts and seek potential best practices, among other efforts. While DHS has made significant strides in strengthening aviation security, it still is in the early stages of developing a comprehensive approach to ensuring inbound air cargo security. Coast Guard Acquisitions and Non-Homeland Security Missions: The Coast Guard needs to improve the management of its acquisitions and continue to enhance its security mission while meeting other mission responsibilities. In 2004, we recommended that the Coast Guard improve its management of the Deepwater program by strengthening key management and oversight activities, implementing procedures to better ensure contractor accountability, and controlling future costs by promoting competition.[Footnote 22] In April 2006, we reported the Coast Guard had made some progress in addressing these recommendations. For example, the Coast Guard has addressed our recommendation to ensure better contractor accountability by providing for better input from U.S. Coast Guard performance monitors.[Footnote 23] However, even with these improvements, acquisition and contract management issues that we reported on previously continue to be challenges to the Coast Guard. For example, within the Deepwater program, an updated class of patrol boats has been removed from service and its replacement, a new cutter class, has been delayed due to design concerns. While the Coast Guard recently announced that it will be taking a more active role in Deepwater acquisitions and noted that many of the issues that led to these acquisition problems are being addressed, it is too soon to tell how effective these changes will be. Further, the Coast Guard has acquisition challenges other than just the Deepwater program. For example, the Coast Guard's timeline for achieving full operating capability for its search and rescue communications system, Rescue 21, was delayed from 2006 to 2011, and the estimated total acquisition cost increased. The Coast Guard has made progress in balancing its homeland security and traditional missions. The Coast Guard is unlike many other DHS components because it has substantial missions not related to homeland security. These missions include maritime navigation, icebreaking, protecting the marine environment, marine safety, and search and rescue for mariners in distress. Furthermore, unpredictable natural disasters, such as Hurricane Katrina, can place intense demands on all Coast Guard resources. The Coast Guard must continue executing these traditional missions and balance those responsibilities with its homeland security obligations, which have increased significantly since September 11. Border Security and the Regulation of Trade: DHS has made some progress but still faces an array of challenges in securing the border while improving the regulation of commercial trade.[Footnote 24] Since 2005, DHS agencies have made some progress in implementing our recommendations to refine the screening of foreign visitors to the United States, target potentially dangerous cargo, and provide the personnel necessary to effectively fulfill border security and trade agency missions. As of January 2006, DHS had a pre-entry screening capability in place in overseas visa issuance offices, and an entry identification capability at 115 airports, 14 seaports, and 154 land ports of entry. Furthermore, the Secretary of Homeland Security has made risk management at ports and all critical infrastructure facilities a key priority for DHS. In addition, DHS developed performance goals and measures for its trade processing system and implemented a testing and certification process for its officers to provide better assurance of effective cargo examination targeting practices. However, efforts to assess and mitigate risks of DHS's and the Department of State's implementation of the Visa Waiver Program remain incomplete, increasing the risk that the program could be exploited by someone who intends harm to the United States. Further, many of DHS's border-related performance goals and measures are not fully defined or adequately aligned with one another, and some performance targets are not realistic. CBP is not systematically incorporating inspection results into its cargo screening system because it has not yet fully implemented a system that will report details on its security inspections nationwide to allow management to analyze those inspections. Other trade and visitor screening systems have weaknesses that must be overcome to better ensure border and trade security. For example, deficiencies in the identification of counterfeit documentation at land border crossings into the United States create vulnerabilities that terrorists or others involved in criminal activity could exploit. We also reported that DHS's Container Security Initiative to target and inspect high-risk cargo containers at foreign ports before they leave for the United States has been challenged by staffing imbalances, the lack of minimum technical requirements for inspection equipment used at foreign ports, and insufficient performance measures to assess the effectiveness of targeting and inspection activities. We are currently reviewing this program to ascertain what progress CBP has made in addressing these challenges. Enforcement of Immigration Laws: DHS has taken some actions to improve enforcement of immigration laws, including worksite immigration laws, but the number of resources devoted to enforcing immigration laws is limited given that there are an estimated 12 million illegal aliens residing in the United States. DHS has strengthened some aspects of immigration enforcement, including allocating more investigative work years to immigration functions than the Immigration and Naturalization Service did prior to the creation of DHS. Nevertheless, effective enforcement will require more attention to efficient resource use and updating outmoded management systems.[Footnote 25] In April 2006, ICE announced an interior enforcement strategy to bring criminal charges against employers who knowingly hire unauthorized workers. ICE has also reported increases in the number of criminal arrests and indictments for these violations since fiscal year 2004. In addition, ICE has plans to shift responsibility for identifying incarcerated criminal aliens eligible for removal from the United States from the Office of Investigations to its Office of Detention and Removal, freeing those investigative resources for other immigration and customs investigations. ICE has also begun to introduce principles of risk management into the allocation of its investigative resources. However, enforcement of immigration enforcement laws needs to be strengthened and significant management challenges remain. DHS's ability to locate and remove millions of aliens who entered the country illegally or overstayed the terms of their visas is questionable, and implementing an effective worksite enforcement program remains an elusive goal. ICE's Office of Investigations has not conducted a comprehensive risk assessment of the customs and immigration systems to determine the greatest risks for exploitation by criminals and terrorists. This office also lacks outcome-based performance goals that relate to its objective of preventing the exploitation of systemic vulnerabilities in customs and immigration systems, and it does not have sufficient systems in place to help ensure systematic monitoring and communication of vulnerabilities discovered during its investigations. Moreover, the current employment verification process used to identify workers ineligible for employment in the United States has not fundamentally changed since its establishment in 1986, and ongoing weaknesses have undermined its effectiveness. We have recommended that DHS take actions to help address these weaknesses and to strengthen the current process by issuing final regulations on changes to the employment verification process which will reduce the number of documents suitable for proving eligibility to work in the United States. Some other countries require foreign workers to present work authorization documents at the time of hire and require employers to review these documents and report workers' information to government agencies for collecting taxes and social insurance contributions, and conducting worksite enforcement actions. Provision of Immigration Services: Although DHS has made progress in reducing its backlog of immigration benefit applications, improvements are still needed in the provision of immigration services, particularly by strengthening internal controls to prevent fraud and inaccuracy.[Footnote 26] Since 2005, DHS has enhanced the efficiency of certain immigration services. For example, U.S. Citizenship and Immigration Services (USCIS) estimated that it had reduced its backlog of immigration benefits applications from a peak of 3.8 million cases to 1.2 million cases from January 2004 to June 2005. USCIS has also established a focal point for immigration fraud, outlined a fraud control strategy that relies on the use of automation to detect fraud, and is performing fraud assessments to identify the extent and nature of fraud for certain benefits. However, DHS still faces significant challenges in its ability to effectively provide immigration services while at the same time protecting the immigration system from fraud and mismanagement. USCIS may have adjudicated tens of thousands of naturalization applications without alien files, and adjudicators were not required to record whether the alien file was available when they adjudicated the application. Without these files, DHS may not be able to take enforcement action against an applicant and could also approve an application for an ineligible applicant. In response to our report, USCIS recently enacted a policy that requires the adjudicator to record whether the alien file was available when they adjudicated the application. In addition, USCIS has not implemented important aspects of our internal control standards or fraud control best practices identified by leading audit organizations. Such best practices would include (1) a comprehensive risk management approach, (2) mechanisms for ongoing monitoring during the course of normal activities, (3) clear communication agencywide regarding how to balance production-related goals with fraud-prevention activities, and (4) performance goals for fraud prevention. Disaster Preparedness and Response: We have reported that DHS needs to more effectively coordinate disaster preparedness, response, and recovery efforts.[Footnote 27] Between the time that FEMA became part of DHS in March 2003 and Hurricane Katrina hit in late August 2005, its responsibilities had been dispersed and its role within DHS continued to evolve. Hurricane Katrina severely tested disaster management at the federal, state, and local levels and revealed weaknesses in the basic elements of preparing for, responding to, and recovering from any catastrophic disaster. Our analysis showed the need for (1) clearly defined and understood leadership roles and responsibilities; (2) the development of the necessary disaster capabilities; and (3) accountability systems that effectively balance the need for fast and flexible response against the need to prevent waste, fraud, and abuse. In September 2006, we recommended that Congress give federal agencies explicit authority to take actions to prepare for all types of catastrophic disasters when there is warning. We also recommended that DHS (1) rigorously re-test, train, and exercise its recent clarification of the roles, responsibilities, and lines of authority for all levels of leadership, implementing changes needed to remedy identified coordination problems; (2) direct that the National Response Plan (NRP) base plan and its supporting Catastrophic Incident Annex be supported by more robust and detailed operational implementation plans; (3) provide guidance and direction for federal, state, and local planning, training, and exercises to ensure such activities fully support preparedness, response, and recovery responsibilities at a jurisdictional and regional basis; (4) take a lead in monitoring federal agencies' efforts to prepare to meet their responsibilities under the NRP and the interim National Preparedness Goal; and (5) use a risk management approach in deciding whether and how to invest finite resources in specific capabilities for a catastrophic disaster. DHS has made revisions to the NRP and released its Supplement to the Catastrophic Incident Annex--both designed to further clarify federal roles and responsibilities and relationships among federal, state and local governments and responders. However, these revisions have not been rigorously tested. DHS is working on additional revisions to the NRP and the National Incident Management System and recently informed Congress the revisions to the NRP may not be complete by the scheduled June 1, 2007 target date. Thus, it is unlikely that any changes will be clearly communicated, understood, and effectively tested prior to the 2007 Hurricane Season, which begins in June. DHS has also announced a number of actions intended to improve readiness and response based on our work and the work of congressional committees and the Administration. For example, DHS is currently reorganizing FEMA as required by the fiscal year 2007 DHS appropriations act.[Footnote 28] One major objective of this reorganization is to integrate responsibility and accountability for disaster preparedness and response within DHS by placing the responsibility for both within FEMA. DHS has also announced a number of other actions to improve readiness and response, such as mass care and shelter, in which FEMA rather than the Red Cross, will now have the lead. However, there is little information available on the extent to which these changes are tested and operational. Finally, in its desire to provide assistance quickly following Hurricane Katrina, DHS was unable to keep up with the magnitude of needs to confirm the eligibility of victims for disaster assistance, or ensure that there were provisions in contracts for response and recovery services to ensure fair and reasonable prices in all cases. We recommended that DHS create accountability systems that effectively balance the need for fast and flexible response against the need to prevent waste, fraud, and abuse. We also recommended that DHS provide guidance on advance procurement practices (pre-contracting) and procedures for those federal agencies with roles and responsibilities under the NRP so that these agencies can better manage disaster-related procurement, and establish an assessment process to monitor agencies' continuous planning efforts for their disaster-related procurement needs and the maintenance of capabilities.[Footnote 29] For example, we identified a number of emergency response practices in the public and private sectors that provide insight into how the federal government can better manage its disaster-related procurements. These include both developing knowledge of contractor capabilities and prices and establishing vendor relationships prior to the disaster and establishing a scalable operations plan to adjust the level of capacity to match the response with the need. FEMA had taken some action on these recommendations by entering into advance contracts for various goods, supplies, and services, such as debris removal. However, DHS has not implemented our recommendation to develop guidance on advance procurement practices and procedures for those federal agencies and other partners, such as the Red Cross, with roles and responsibilities under the NRP. Actions Needed to Strengthen DHS's Transformation and Integration Efforts: To be removed from our high-risk list, agencies need to develop a corrective action plan that defines the root causes of identified problems, identifies effective solutions to those problems, and provides for substantially completing corrective measures in the near term. Such a plan should include performance measures, metrics and milestones to measure their progress. Agencies should also demonstrate significant progress in addressing the problems identified in their corrective action plan. This should include a program to monitor and independently validate progress. Finally, agencies, in particular top leadership, must demonstrate a commitment to sustain initial improvements. This would include a strong commitment to address the risk(s) that put the program or function on the high-risk list and provide for the allocation of sufficient people and resources (capacity) to resolve the risk(s) and ensure that improvements are sustainable over the long term. In the spring of 2006, DHS provided us a draft corrective action plan for addressing its transformation challenges. This plan addressed major management areas we had previously identified as key to DHS's transformation--management integration through the DHS management directorate and financial, information, acquisition, and human capital management. The plan identified an overall goal to develop and implement key department wide processes and systems to support DHS's transformation into a department capable of planning, operating, and managing as one effective department. In the short term, the plan sought to produce significant improvements over the next 7 years that further DHS's ability to operate as one department. Although the plan listed accomplishments and general goals for the management functions, it did not contain (1) objectives linked to those goals that are clear, concise, and measurable; (2) specific actions to implement those objectives; (3) information linking sufficient people and resources to implement the plan; or (4) an evaluation program to monitor and independently validate progress toward meeting the goals and measuring the effectiveness of the plan. As of May 2007, DHS has not submitted a corrective action plan to OMB. According to an official at OMB, this is one of the few high-risk areas that have not produced a final corrective action plan. In addition to developing an effective corrective action plan, agencies must show that significant progress has taken place in improving performance in the areas identified in its corrective action plan. While our work has noted progress at DHS, for us to remove the DHS implementation and transformation from our high-risk list, we need to be able to independently assure ourselves and Congress that DHS has implemented many of our past recommendations, or has taken other corrective actions to address the challenges we identified. However, DHS has not made its management or operational decisions transparent enough so that Congress can be sure it is economically, efficiently, effectively, ethically, and equitably using the billions of dollars in funding it receives annually, and is providing the levels of security called for in numerous legislative requirements and presidential directives. Our work for Congress assessing DHS's operations has been significantly hampered by long delays in granting us access to program documents and officials, or by questioning our access to information needed to conduct our reviews. We have processes for obtaining information from departments and agencies across the federal government that work well. DHS's process-- involving multiple layers of review by department-and component-level liaisons and attorneys regarding whether to provide us the requested information--does not work as smoothly. DHS's processes have impeded our efforts to carry out our mission by delaying access to documents that we require to assess the department's operations. We have occasionally worked with DHS management to establish a cooperative process--for example, reviewing sensitive documents at a particular agency location--in an effort to not only to maintain a productive working relationship with the department but also to meet the needs of our congressional requesters in a timely manner. I have spoken to Secretary Chertoff who pledged to make access a higher priority and have met with Undersecretary Schneider who also assured us of his cooperation. We are encouraged by these statements and look forward to better relations with the department. We recognize that the department has legitimate interests in protecting certain types of sensitive information from public disclosure. We share that interest as well and follow strict security guidelines in handling such information. We similarly recognize that agency officials will need to make judgments with respect to the manner and the processes they use in response to our information requests. However, to date, because of the processes adopted to make these judgments, GAO has often not been able to do its work in a timely manner. We have been able to eventually obtain information and to answer audit questions, but the delays we have experienced at DHS have impeded our ability to conduct audit work efficiently and to provide timely information to congressional clients. Finally, to be removed from our high-risk list, any progress that occurs must be sustainable over the long term. DHS's leaders need to make and demonstrate a commitment to implementing a transformed organization. The Secretary has stated such a commitment, most prominently as part of his "second stage review" in the summer of 2005, and more recently in remarks made at George Washington University's Homeland Security Policy Institute. However, appropriate follow-up is required to assure that transformation plans are effectively implemented and sustained, to include the allocation of adequate resources to support transformation efforts. In this regard, we were pleased when DHS established a Business Transformation Office, but we believe that the office's effectiveness was limited because the department did not give it the authority and responsibility needed to be successful. We understand that this office has recently been eliminated. Further, department leaders can show their commitment to transforming DHS by acting on recommendations made by the Congress, study groups, and accountability organizations such as its Office of the IG and GAO. Although we have also seen some progress in this area, it is not enough for us to conclude that DHS is committed to and capable of quickly incorporating corrective actions into its operations. Therefore, until DHS produces an acceptable corrective action plan, demonstrates progress reforming its key management functions, and dedicates the resources necessary to sustain this progress, it will likely remain on our high-risk list. Mr. Chairman and members of the subcommittee, this completes my prepared statement. I would be happy to respond to any questions that you or other members of the subcommittee may have at this time. Contacts and Acknowledgements: For information about this testimony, please contact Norman Rabkin, Managing Director, Homeland Security and Justice Issues, at (202) 512- 8777, or rabkinn@gao.gov or Bernice Steinhardt, Director, Strategic Issues at 202-512-6806 or steinhardtb@gao.gov. Other individuals making key contributions to this testimony include Christopher Conrad, Anthony DeFrank, and Sarah Veale. [End of section] Appendix I: Related GAO Products: Implementing and Transforming the Department of Homeland Security: Implementation and Transformation: High-Risk Series: An Update, GAO-07-310 (Washington, D.C.: Jan. 31, 2007). Suggested Areas for Oversight for the 110th Congress, GAO-07-235R (Washington, D.C.: Nov. 17, 2006). Homeland Security: DHS Is Addressing Security at Chemical Facilities, but Additional Authority Is Needed, GAO-06-899T (Washington, D.C.: June 21, 2006). Homeland Security: Guidance and Standards Are Needed for Measuring the Effectiveness of Agencies' Facility Protection Efforts, GAO-06-612 (Washington, D.C.: May 31, 2006). Homeland Security: DHS Needs to Improve Ethics-Related Management Controls for the Science and Technology Directorate, GAO-06-206 (Washington, D.C.: Dec. 22, 2005). Critical Infrastructure Protection: Department of Homeland Security Faces Challenges in Fulfilling Cybersecurity Responsibilities, GAO-05- 434 (Washington, D.C.: May 26, 2005). Homeland Security: Overview of Department of Homeland Security Management Challenges, GAO-05-573T (Washington, D.C.: April 20, 2005). Results-Oriented Government: Improvements to DHS's Planning Process Would Enhance Usefulness and Accountability, GAO-05-300 (Washington, D.C.: March 31, 2005). Department of Homeland Security: A Comprehensive and Sustained Approach Needed to Achieve Management Integration, GAO-05-139 (Washington, D.C.: March 16, 2005). Homeland Security: Further Actions Needed to Coordinate Federal Agencies' Facility Protection Efforts and Promote Key Practices, GAO- 05-49 (Washington, D.C.: Nov. 30, 2004). Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned for a Department of Homeland Security and Other Federal Agencies, GAO- 03-293SP (Washington, D.C.: Nov. 14, 2002). Determining Performance and Accountability Challenges and High Risks, GAO-01-159SP (Washington, D.C.: Aug. 2000). Financial Management and Internal Controls: Financial Management Systems: DHS Has an Opportunity to Incorporate Best Practices in Modernization Efforts, GAO-06-553T (Washington, D.C.: March 29, 2006). Financial Management: Department of Homeland Security Faces Significant Financial Management Challenges, GAO-04-774. Washington, D.C.: July 19, 2004). Information Technology: Homeland Security: DHS Enterprise Architecture Continues to Evolve but Improvements Needed, GAO-07-564 (Washington, D.C.: May 9, 2007). Information Technology: DHS Needs to Fully Define and Implement Policies and Procedures for Effectively Managing Investments, GAO-07- 424 (Washington, D.C.: April 27, 2007). Information Technology: Customs Has Made Progress on Automated Commercial Environment System, but It Faces Long-Standing Management Challenges and New Risks, GAO-06-580 (Washington, D.C.: May 31, 2006). Information Sharing: DHS Should Take Steps to Encourage More Widespread Use of Its Program to Protect and Share Critical Infrastructure Information, GAO-06-383 (Washington, D.C.: April 17, 2006). Homeland Security: Progress Continues, but Challenges Remain on Department's Management of Information Technology, GAO-06-598T (Washington, D.C.: March 29, 2006). Information Technology: Management Improvements Needed on Immigration and Customs Enforcement's Infrastructure Modernization Program, GAO- 05- 805 (Washington, D.C.: Sept. 7, 2005.) Information Security: Department of Homeland Security Needs to Fully Implement Its Security Program. GAO-05-700 (Washington, D.C.: June 17, 2005). Information Technology: Federal Agencies Face Challenges in Implementing Initiatives to Improve Public Health Infrastructure, GAO- 05-308 (Washington, D.C.: June 10, 2005). Information Technology: Customs Automated Commercial Environment Program Progressing, but Need for Management Improvements Continues. GAO-05-267 (Washington, D.C.: March 14, 2005). Department of Homeland Security: Formidable Information and Technology Management Challenge Requires Institutional Approach, GAO-04-702 (Washington, D.C.: Aug. 27, 2004). Human Capital Systems: Budget Issues: FEMA Needs Adequate Data, Plans, and Systems to Effectively Manage Resources for Day-to-Day Operations, GAO-07-139 (Washington, D.C.: Jan. 19, 2007). Border Security: Stronger Actions Needed to Assess and Mitigate Risks of the Visa Waiver Program, GAO-06-854 (Washington, D.C.: July 28, 2006). Information on Immigration Enforcement and Supervisory Promotions in the Department of Homeland Security's Immigration and Customs Enforcement and Customs and Border Protection, GAO-06-751R (Washington, D.C.: June 13, 2006). Homeland Security: Visitor and Immigrant Status Program Operating, but Management Improvements Are Still Needed, GAO-06-318T (Washington, D.C.: Jan. 25, 2006). Department of Homeland Security: Strategic Management of Training Important for Successful Transformation, GAO-05-888 (Washington, D.C.: Sept. 23, 2005). Acquisition Management: Interagency Contracting: Improved Guidance, Planning, and Oversight Would Enable the Department of Homeland Security to Address Risks, GAO- 06-996 (Washington, D.C.: Sept. 27, 2006). Homeland Security: Challenges in Creating an Effective Acquisition Organization, GAO-06-1012T (Washington, D.C.: July 27, 2006). Homeland Security: Successes and Challenges in DHS's Efforts to Create an Effective Acquisition Organization, GAO-05-179 (Washington, D.C.: March 29, 2005). Homeland Security: Further Action Needed to Promote Successful Use of Special DHS Acquisition Authority, GAO-05-136 (Washington, D.C.: Dec. 15, 2004). Transportation Security: Aviation Security: Federal Efforts to Secure U.S.-Bound Air Cargo Are in the Early Stages and Could Be Strengthened, GAO-07-660 (Washington, D.C.: April 30, 2007). Aviation Security: TSA's Change to its Prohibited Items List Has Not Resulted in Any Reported Public Safety Incidents, but the Impact of the Change on Screening Operations is Inconclusive, GAO-07-623R. (Washington, D.C.: April 25, 2007). Aviation Security: Risk, Experience, and Customer Service Drive Changes to Airline Passenger Screening Procedures, but Evaluation and Documentation of Proposed Changes Could Be Improved, GAO-07-634 (Washington, D.C.: April 16, 2007). Aviation Security: TSA's Staffing Allocation Model Is Useful for Allocating Staff among Airports, but Its Assumptions Should Be Systematically Reassessed, GAO-07-299 (Washington, D.C.: Feb. 28, 2007). Aviation Security: Progress Made in Systematic Planning to Guide Key Investment Decisions, but More Work Remains, GAO-07-448T, (Washington, D.C.: Feb. 13, 2007). Transportation Security Administration: Oversight of Explosive Detection Systems Maintenance Contracts Can Be Strengthened, GAO-06-795 (Washington, D.C.: July 31, 2006). Aviation Security: TSA Oversight of Checked Baggage Screening Procedures Could Be Strengthened, GAO-06-869 (Washington, D.C.: July 28, 2006). Rail Transit: Additional Federal Leadership Would Enhance FTA's State Safety Oversight Program, GAO-06-821 (Washington, D.C.: July 26, 2006). Aviation Security: Management Challenges Remain for the Transportation Security Administration's Secure Flight Program, GAO-06-864T (Washington, D.C.: June 14, 2006). Aviation Security: Enhancements Made in Passenger and Checked Baggage Screening, but Challenges Remain, GAO-06-371T (Washington, D.C.: April 4, 2006). Aviation Security: Progress Made to Set Up Program Using Private-Sector Airport Screeners, but More Work Remains, GAO-06-166 (Washington, D.C.: March 31, 2006). Aviation Security: Significant Management Challenges May Adversely Affect Implementation of the Transportation Security Administration's Secure Flight Program, GAO-06-374T (Washington, D.C.: Feb. 9, 2006). Aviation Security: Federal Air Marshal Service Could Benefit from Improved Planning and Controls, GAO-06-203 (Washington, D.C.: Nov. 28, 2005). Aviation Security: Federal Action Needed to Strengthen Domestic Air Cargo Security, GAO-06-76 (Washington, D.C.: Oct. 17, 2005.) Passenger Rail Security: Enhanced Federal Leadership Needed to Prioritize and Guide Security Efforts, GAO-05-851 (Washington, D.C.: Sept. 9, 2005). Aviation Security: Flight and Cabin Crew Member Security Training Strengthened, but Better Planning and Internal Controls Needed, GAO-05- 781 (Washington, D.C.: Sept. 6. 2005). Aviation Safety: Oversight of Foreign Code-Share Safety Program Should Be Strengthened, GAO-05-930 (Washington, D.C.: Aug. 5, 2005). Homeland Security: Agency Resources Address Violations of Restricted Airspace, but Management Improvements Are Needed, GAO-05-928T (Washington, D.C.: July 21, 2005). Aviation Security: Secure Flight Development and Testing Under Way, but Risks Should Be Managed as System Is Further Developed, GAO-05-356 (Washington, D.C.: March 28, 2005). Aviation Security: Systematic Planning Needed to Optimize the Deployment of Checked Baggage Screening Systems, GAO-05-365 (Washington, D.C.: March 15, 2005). Coast Guard Acquisitions and Non-Homeland Security Missions: Coast Guard: Observations on the Fiscal Year 2008 Budget, Performance, Reorganization, and Related Challenges: GAO-07-489T (Washington, D.C.: April 18, 2007). Coast Guard: Status of Efforts to Improve Deepwater Program Management and Address Operational Challenges, GAO-07-575T (Washington, D.C.: March 8, 2007). Coast Guard: Preliminary Observations on Deepwater Program Assets and Management Challenges, GAO-07-446T (Washington, D.C.: Feb. 15, 2007). Coast Guard: Efforts to Improve Management and Address Operational Challenges in the Deepwater Program, GAO-07-460T (Washington, D.C.: Feb. 14, 2007). Homeland Security: Observations on the Department of Homeland Security's Acquisition Organization and on the Coast Guard's Deepwater Program, GAO-07-453T (Washington, D.C.: Feb. 8, 2007). United States Coast Guard: Improvements Needed in Management and Oversight of Rescue System Acquisition, GAO-06-623 (Washington, D.C.: May 31, 2006). Coast Guard: Changes to Deepwater Plan Appear Sound, and Program Management Has Improved, but Continued Monitoring is Warranted, GAO-06- 546 (Washington, D.C.: April 28, 2006). Risk Management: Further Refinements Needed to Assess Risks and Prioritize Protective Measures at Ports and Other Critical Infrastructure, GAO-06-91 (Washington, D.C.: Dec. 15, 2005.) Maritime Security: Enhancements Made, but Implementation and Sustainability Remain Key Challenges, GAO-05-448T (Washington, D.C.: May 17, 2005). Cargo Security: Partnership Program Grants Importers Reduced Scrutiny with Limited Assurance of Improved Security, GA0-05-404 (Washington, D.C.: March 11, 2005). Coast Guard: Station Readiness Improving, but Resource Challenges and Management Concerns Remain, GAO-05-161 (Washington, D.C.: Jan. 31, 2005). Contract Management: Coast Guard's Deepwater Program Needs Increased Attention to Management and Contractor Oversight, GAO-04-380 (Washington, D.C.: March 9, 2004). Border Security and the Regulation of Trade: Border Security: US-VISIT Program Faces Strategic, Operational, and Technological Challenges at Land Ports of Entry, GAO-07-248 (Washington, D.C.: Dec. 6, 2006). Border Security: Stronger Actions Needed to Assess and Mitigate Risks of the Visa Waiver Program, GAO-06-854 (Washington, D.C.: July 28, 2006). Information Technology: Customs Has Made Progress on Automated Commercial Environment System, but It Faces Long-Standing Management Challenges and New Risks, GAO-06-580 (Washington, D.C.: May 31, 2006). Border Security: Key Unresolved Issues Justify Reevaluation of Border Surveillance Technology Program, GAO-06-295 (Washington, D.C.: Feb. 22, 2006). Homeland Security: Recommendations to Improve Management of Key Border Security Program Need to Be Implemented, GAO-06-296 (Washington, D.C.: Feb. 14, 2006). Border Security: Strengthened Visa Process Would Benefit from Improvements in Staffing and Information Sharing, GAO-05-859 (Washington, D.C.: Sept. 13, 2005). Border Security: Opportunities to Increase Coordination of Air and Marine Assets, GAO-05-543 (Washington, D.C.: Aug. 12, 2005). Border Security: Actions Needed to Strengthen Management of Department of Homeland Security's Visa Security Program, GAO-05-801 (Washington, D.C.: July 29, 2005). Border Patrol: Available Data on Interior Checkpoints Suggest Differences in Sector Performance, GAO-05-435 (Washington, D.C.: July 22, 2005). Enforcement of Immigration Laws: Immigration Enforcement: Weaknesses Hinder Employment Verification and Worksite Enforcement Efforts, GAO-06-895T (Washington, D.C.: June 19, 2006). Information on Immigration Enforcement and Supervisory Promotions in the Department of Homeland Security's Immigration and Customs Enforcement and Customs and Border Protection, GAO-06-751R (Washington, D.C.: June 13, 2006). Homeland Security: Contract Management and Oversight for Visitor and Immigrant Status Program Need to Be Strengthened, GAO-06-404 (Washington, D.C.: June 9, 2006). Homeland Security: Better Management Practices Could Enhance DHS's Ability to Allocate Investigative Resources, GAO-06-462T (Washington, D.C.: March 28, 2006). Immigration Enforcement: Weaknesses Hinder Employment Verification and Worksite Enforcement Efforts, GAO-05-813 (Washington, D.C.: Aug. 31, 2005). Provision of Immigration Services: Immigration Benefits: Additional Efforts Needed to Help Ensure Alien Files Are Located when Needed, GAO-07-85 (Washington, D.C.: Oct. 27, 2006). Immigration Benefits: Additional Controls and a Sanctions Strategy Could Enhance DHS's Ability to Control Benefit Fraud, GAO-06-259 (Washington, D.C.: March 10, 2006). Immigration Benefits: Improvements Needed to Address Backlogs and Ensure Quality of Adjudications, GAO-06-20 (Washington, D.C.: Nov. 21, 2005). Immigration Services: Better Contracting Practices Needed at Call Centers, GAO-05-526 (Washington, D.C.: June 30, 2005.) Disaster Preparedness and Response: Catastrophic Disasters: Enhanced Leadership, Capabilities, and Accountability Controls Will Improve the Effectiveness of the Nation's Preparedness, Response, and Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6, 2006). Disaster Relief: Governmentwide Framework Needed to Collect and Consolidate Information to Report on Billions in Federal Funding for the 2005 Gulf Coast Hurricanes, GAO-06-834 (Washington, D.C.: Sept. 6, 2006). Disaster Preparedness: Limitations in Federal Evacuation Assistance for Health Facilities Should be Addressed, GAO-06-826 (Washington, D.C.: July 20, 2006). Expedited Assistance for Victims of Hurricanes Katrina and Rita: FEMA's Control Weaknesses Exposed the Government to Significant Fraud and Abuse, GAO-06-655 (Washington, D.C.: June 16, 2006). Hurricane Katrina: Comprehensive Policies and Procedures Are Needed to Ensure Appropriate Use of and Accountability for International Assistance, GAO-06-460 (Washington, D.C.: April 6, 2006). Continuity of Operations: Agency Plans Have Improved, but Better Oversight Could Assist Agencies in Preparing for Emergencies, GAO-05- 577 (Washington, D.C.: April 28, 2005). FOOTNOTES [1] GAO, Determining Performance and Accountability Challenges and High Risks, GAO-01-159SP (Washington, D.C.: Nov. 1, 2000). [2] Homeland Security Act of 2002, Pub. L. No. 107-296, 116 Stat. 2135 (Nov. 25, 2002). [3] GAO, Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned for a Department of Homeland Security and Other Federal Agencies, GAO-03-293SP (Washington, D.C.: Nov. 14, 2002). [4] GAO, Suggested Areas for Oversight for the 110th Congress, GAO-07- 235R (Washington, D.C.: Nov. 17, 2006). [5] GAO, Results Oriented Government: Improvements to DHS's Planning Process Would Enhance Usefulness and Accountability, GAO-05-300 (Washington, D.C.: March 31, 2005); Homeland Security: Better Management Practices Could Enhance DHS's Ability to Allocate Investigative Resources, GAO-06-462T (Washington, D.C.: March 28, 2006); Border Patrol: Available Data on Interior Checkpoints Suggest Differences in Sector Performance, GAO-05-435 (Washington, D.C.: July 22, 2005). [6] Improving America's Security Act of 2007, S. 4, 110th Cong. � 1601 (2007). [7] GAO, Aviation Security: Significant Management Challenges May Adversely Affect Implementation of the Transportation Security Administration's Secure Flight Program, GAO-06-374T (Washington, D.C.: Feb. 9, 2006); Maritime Security: Enhancements Made, but Implementation and Sustainability Remain Key Challenges, GAO-05-448T (Washington, D.C.: May 17, 2005); Homeland Security: Better Management Practices Could Enhance DHS's Ability to Allocate Investigative Resources, GAO-06- 462T (Washington, D.C.: March 28, 2006); and Homeland Security: DHS Is Addressing Security at Chemical Facilities, but Additional Authority Is Needed, GAO-06-899T (Washington, D.C.: June 21, 2006). [8] Department of Homeland Security, Office of Inspector General. Independent Auditors' Report on DHS' FY 2006 Financial Statements. OIG- 07-10. (Washington, D.C.: Nov. 2006). [9] GAO, Financial Management: Department of Homeland Security Faces Significant Financial Management Challenges, GAO-04-774 (Washington, D.C.: July 19, 2004). [10] GAO, Homeland Security: Progress Continues, but Challenges Remain on Department's Management of Information Technology, GAO-06-598T (Washington, D.C.: March 29, 2006). [11] GAO, Homeland Security: DHS Enterprise Architecture Continues to Evolve but Improvements Needed, GAO-07-564 (Washington, D.C.: May 9, 2007). [12] GAO, Information Technology: DHS Needs to Fully Implement Policies and Procedures for Effectively Managing Investments, GAO-07-424 (Washington, D.C.: April 27, 2007). [13] GAO, Department of Homeland Security: Strategic Management of Training Important for Successful Transformation, GAO-05-888 (Washington, D.C.: Sept. 23, 2005); Information on Immigration Enforcement and Supervisory Promotions in the Department of Homeland Security's Immigration and Customs Enforcement and Customs and Border Protection, GAO-06-751R (Washington, D.C.: June 13, 2006); Homeland Security: Visitor and Immigrant Status Program Operating, but Management Improvements Are Still Needed, GAO-06-318T (Washington, D.C.: Jan. 25, 2006); and Border Security: Stronger Actions Needed to Assess and Mitigate Risks of the Visa Waiver Program, GAO-06-854 (Washington, D.C.: July 28, 2006). [14] GAO, Homeland Security: Overview of Department of Homeland Security Management Challenges, GAO-05-573T (Washington, D.C.: April 20, 2005). [15] The Homeland Security Act gave DHS authorization to design a human capital management system to meet its unique missions. In January 2005, DHS announced its final human capital management system regulations. DHS intended to implement a new personnel system in 2005. According to DHS OIG, these delays will impact the cost of implementation, the current development and implementation contract, and the ability to properly manage the workforce. Department of Homeland Security, Office of Inspector General. Major Management Challenges Facing the Department of Homeland Security, OIG-06-14 (Washington, D.C.: Dec. 2005). [16] GAO, Homeland Security: Success and Challenges in DHS's Efforts to Create an Effective Acquisition Organization, GAO-05-179 (Washington, D.C.: March 29, 2005). [17] GAO, Homeland Security: Challenges in Creating an Effective Acquisition Organization, GAO-06-1012T (Washington, D.C.: July 27, 2006). [18] Interagency Contracting: Improved Guidance, Planning, and Oversight Would Enable the Department of Homeland Security to Address Risks, GAO-06-996 (Washington, D.C.: Sept. 27, 2006). [19] GAO, Aviation Security: Flight and Cabin Crew Member Security Training Strengthened, but Better Planning and Internal Controls Needed, GAO-05-781 (Washington, D.C.: Sept. 6, 2005); Aviation Security: Federal Action Needed to Strengthen Domestic Air Cargo Security, GAO-06-76 (Washington, D.C.: Oct. 17, 2005); Rail Transit: Additional Federal Leadership Would Enhance FTA's State Safety Oversight Program, GAO-06-821 (Washington, D.C.: July 26, 2006); and Aviation Security: TSA Oversight of Checked Baggage Screening Procedures Could Be Strengthened, GAO-06-869 (Washington, D.C.: July 28, 2006). [20] GAO, Aviation Security: TSA Oversight of Checked Baggage Screening Procedures Could Be Strengthened, GAO-06-869 (Washington, D.C.: July 28, 2006); Aviation Security: Federal Action Needed to Strengthen Domestic Air Cargo Security, GAO-06-76 (Washington, D.C.: Oct. 17, 2005); and Aviation Security: Enhancements Made in Passenger and Checked Baggage, but Challenges Remain, GAO-06-371T (Washington, D.C.: April 4, 2006); Aviation Security: Federal Efforts to Secure U.S.-Bound Air Cargo Are in the Early Stages and Could Be Strengthened, GAO-07- 660 (Washington, D.C.: April 30, 2007). [21] GAO, Aviation Security: Management Challenges Remain for the Transportation Security Administration's Secure Flight Program, GAO-06- 864T (Washington, D.C.: June 14, 2006). [22] GAO, Contract Management: Coast Guard's Deepwater Program Needs Increased Attention to Management and Contractor Oversight, GAO-04-380 (Washington, D.C.: March 9, 2004). [23] GAO, Coast Guard: Changes to Deepwater Plan Appear Sound, and Program Management Has Improved, but Continued Monitoring is Warranted, GAO-06-546 (Washington, D.C.: April 28, 2006). [24] GAO, Border Security: US-VISIT Program Faces Strategic, Operational, and Technological Challenges at Land Ports of Entry, GAO- 07-248 (Washington, D.C.: Dec. 6, 2006); Border Security: Stronger Actions Needed to Assess and Mitigate Risks of the Visa Waiver Program, GAO-06-854 (Washington, D.C.: July 28, 2006); Border Security: Key Unresolved Issues Justify Reevaluation of Border Surveillance Technology Program, GAO-06-295 (Washington, D.C.: Feb. 22, 2006); Information Technology: Customs Has Made Progress on Automated Commercial Environment System, but It Faces Long-Standing Management Challenges and New Risks, GAO-06-580 (Washington, D.C.: May 31, 2006); and Homeland Security: Recommendations to Improve Management of Key Border Security Program Need to Be Implemented, GAO-06-296 (Washington, D.C.: Feb. 14, 2006). [25] GAO, Information on Immigration Enforcement and Supervisory Promotions in the Department of Homeland Security's Immigration and Customs Enforcement and Customs and Border Protection, GAO-06-751R (Washington, D.C.: June 13, 2006); Immigration Enforcement: Weaknesses Hinder Employment Verification and Worksite Enforcement Efforts, GAO-06- 895T (Washington, D.C.: June 19, 2006); and Homeland Security: Better Management Practices Could Enhance DHS's Ability to Allocate Investigative Resources, GAO-06-462T (Washington, D.C.: March 28, 2006). [26] GAO, Immigration Benefits: Additional Efforts Needed to Help Ensure Alien Files Are Located when Needed, GAO-07-85 (Washington, D.C.: Oct. 27, 2006); Immigration Benefits: Additional Controls and a Sanctions Strategy Could Enhance DHS's Ability to Control Benefit Fraud, GAO-06-259 (Washington, D.C.: March 10, 2006); and Immigration Benefits: Improvements Needed to Address Backlogs and Ensure Quality of Adjudications, GAO-06-20 (Washington, D.C.: Nov. 21, 2005). [27] GAO, Catastrophic Disasters: Enhanced Leadership, Capabilities, and Accountability Controls Will Improve the Effectiveness of the Nation's Preparedness, Response, and Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6, 2006). [28] Pub. L. No. 109-295, 120 Stat. 1355 (Oct. 4, 2006). [29] See GAO-06-618. 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